Case Law Details
Case Name : Dana India Pvt. Ltd. Vs DCIT (ITAT Pune)
Appeal Number : ITA No. 1731/Pun/2018
Date of Judgement/Order : 02/11/2022
Related Assessment Year : 2014-15
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Dana India Pvt. Ltd. Vs DCIT (ITAT Pune)
ITAT Pune held that foreign exchange gain/loss which has arisen from exports/imports of the product/materials which are in the ordinary course of business of the assesses are included as operating cost.
Facts-
The issue in the present case is that the assesse treated the Foreign Exchange fluctuation gain as an operating revenue, whereas, the Transfer Pricing Officer (TPO)/Assessing Officer (AO), based on their decision on Rule 10TA of the Income Tax Rules of 1962, considered the fluctuation gain as non-operating revenue, resulting and influence in the assessor’s capacity to calculate its profit level indicator (PLI).
Conclusion-
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